March 2010

Spraying with flammable liquids (paints) is a topic that needs to be revisited frequently. Although best practice standards- of which National Fire Protection Association (NFPA) 33 is considered the “bible”- have been around for decades now, still many people do not understand or implement proper controls.

The term “flammable liquid” is defined by NFPA as a liquid that emits vapors less than 100°F and that sustain combustion (the term that defines this process is “flash point”). Several factors make flammable vapors dangerous:

üThe low flash point means that unlike liquids with higher flashpoints, they do not need to be exposed to a heat source in order to be ignited.

üMost common flammable liquids the vapors are heavier than air and therefore sink to floor level and tend to disperse less readily.

üThe vapors burn very quickly in what is called a “deflagration”- essentially an explosion. They also have a very high heat release.

üFires are difficult to extinguish. Water can be used to extinguish, but non water-miscible liquids will present more hazards (such as floating puddles of flammable liquids ready to spread the fire elsewhere).

How to tell

Flammable liquid containers must display a distinct red label in order to comply with Department of Transportation (DOT) regulations. Don’t count on just reading the label, however, as the label might not be on the containers (e.g. it may have fallen off). Obtain a “material safety data sheet (MSDS) from the vendor/supplier of the liquid. This will detail the liquids along with the safety precautions.

For the purpose of this blog, we can’t go into great detail (we’ll give the Reader’s Digest version), and we’ll not cover storagein detail (this is another standard- NFPA 30)- but as an overview, below are some key ways to control the exposure (again- NFPA 33 outlines these in detail). Note that any spraying should be done in a UL listed or Factory Mutual Approved spray booth if possible since this helps with the below controls and the design is such that lends itself to easier cleaning, etc. (e.g. equipped with seamless/smooth metal interior walls).

Ignition Source Control

All electrical systems near the spray booth should be designed to prevent inadvertent ignition of flammable spray vapors. All electrical and lighting fixtures within a twenty feet horizontal or ten feet vertical distance from the booth need to be protected in accordance with NFPA 70 NFPA 70 'National Electric Code'. NFPA 70 'National Electric Code' specifies that Class I, Division 1 & 2 electrical should be installed. This diagram illustrates the general requirement:

Ventilation:

The purpose of ventilation is to prevent accumulation of vapors. The best way to do this is with a spray booth. The booth should be mechanically exhausted to have a cross-sectional airflow of 100 feet per minute (CFM) in order to remove the flammable vapors. It is also imperative to maintain the concentration of vapor in the exhaust air stream below 25 percent of the lower flammable limit. This requires a sufficient flow of air moving through the booth at a sufficiently high velocity.

Note that the equipment (fans) that moves the vapors must not themselves be an ignition source, therefore, they should be constructed of non-ferrous metals or other non-spark generating materials.

Equipment (spray guns) should be interlocked with ventilation of the booth in order to assure that the ventilation is on (and take possible human error out of the process).

This may go without saying, but the air must be exhausted safely outside the building (make sure all “clean-air” / EPA regulations are adhered to by filtering/scrubbing the air).

Fire Suppression

The area/booth should have fire suppression- either automatic sprinkler protection or automatic fire suppression (such as an FM-200 chemical extinguishing system). Despite good dilution, ignition source control, and human element factors, a fire can still develop. Make sure that nozzles are protected from overspray of paint (approved cloth bags can be used, however, make sure they are clean). It is also recommended that sprinkler heads or fire suppression nozzles be located within ductwork (e.g. leading outside).

Paint Storage

Make sure that all flammable liquids (paints) are stored in accordance with NFPA 30 Storage of Flammable Liquids. These can be in an approved storage room or in Underwriters Lab (UL) listed containers (there is a limit though). A small supply (generally less than 25g) can be in use outside the storage, but it should be placed in safety cans (UL/FM approved).

Human Element

Last but not least, the controls that rely on the operator are also very important. These include:

ØEquipment and storage containers should be bonded and grounded to prevent static electricity buildup (ignition source).

ØThere should be a regular documented cleaning schedule to prevent excessive accumulations of overspray residue. Use of non-spark generating materials.

ØFilters should be changed regularly. There are various means of filtering the air, but the most common is non-woven cloth filters. Check airflow gauges to make sure the filters are not blocking airflow (usually due to clogged filters).

ØPreviously used rags should be placed in self-closing cans during the day, and removed to a safe location outside the building at the end of the working shift.

ØAny portable fans or radios that are not in accordance with NFPA 70 (class I electrical) should not be used within the distances given above (this is a common violation).

ØThough this article concentrated on the fire/property hazards, the health hazards are also critical. Appropriate respirators and personal protective equipment (clothing, eyewear, etc.) should be used by employees. If lead or other metals are involved, there may need to be a further OSHA- required controls.

This blog focused on spray finishing. Many parts/products are being coated by a process known as powder coating. This will be a topic for a future blog, but generally speaking, begin by applying the same principles and much the same controls as above (particularly the human element).

What would you do first? You can refuse to have a compliance officer come onto your work-site, but he will only return with a court order...... Not a good start for an OSHA inspection.

What you should do this at the beginning of the inspection

Ask the Dept of Labor (DOL) compliance officer for identification

Notify your foreman, project manager & safety director that the compliance officers is on the work-site

The compliance officer should be escorted at all times during the inspection

There will be an opening conference which will include the purpose of the inspection and the type of inspection to be performed. The compliance officer may ask to review written safety programs, hazard communication program, training documents, OSHA 300 logs, etc.

Purpose of the Inspection

Employee Complaint

Planned

Drive by

Serious accident and / or injury

Type of Inspection

Complaint

Wall to Wall

Emphasis program focused

The compliance officers will then perform a walk around inspection. The compliance officer may do the following while conducting the inspection.

Take photos

Video tape

Examine job site conditions, job hazard exposures to employees and safety controls in place

Interview employees, specifically competent person at the work-site

Your representative (project manager, safety director, or job foreman) should do the following

Accompany the compliance officer on the inspection

Limit access to specific location the compliance officer discussed in the opening conference

Be truthful with the compliance officer

Take thorough notes

Identify safe practices to the compliance officer

Correct violations immediately

Inquire about results

Do not:

Argue with compliance officer

Discuss inspection with anyone other than your management

Admit to any violations

Interviews

The compliance officer may want to interview personnel

The interview may include supervision and non-supervision employees

Take notes of who was interviewed

Pre-closing Conference

The compliance officer may request certain information. Some of the requested information could include the following.

Safety policies and programs

Training records

Information regarding equipment and machinery that was involved in the inspection

Violations found by the OSHA compliance officer will be discussed during the closing conference.

Recently, Westfield has launched a new corporate blog tailored specifically for the farm and agribusiness industry titled "Grains of Knowledge." The new blog is authored by several experts from Westfield's AgriBusiness division.

Grains of knowledge will be cover a wide variety of topics, including safety tips, news and trends, insurance needs, frequently asked questions and much more.

It is no surprise that working out will benefit us physically. Unfortunately, this time of the year is when those New Years Resolutions to workout start to fade out. Complacency sets in and we go back to our original habits.

Have you ever taken the time to look at fitness as a way to benefit you financially as well? According to an article featuring Peter Brubaker, professor of health and exercise science at Wake Forest University, a regular workout routine can reduce your risk for heart disease, stroke, diabetes, colorectal cancer, breast cancer, bone and joint conditions and sleep apnea. Not only do you rest better and feel better, you can also prevent visits to the doctor! Fewer doctor visits can reduce your out-of-pocket costs which may make your benefits plan less costly. Working out can also help to fight off other health concerns such as stress and depression. When you feel better, you work better, and this can lead to an increase in your productivity at work! These benefit you AND your employer!

Here are some suggestions from Brubaker to increase daily physical activity:

Set a goal of 30 minutes a day of physical activity.

Walk. For most people, the easiest and most efficient activity is simply walking.

Wear a pedometer. Recent studies have shown that people wearing pedometers increase their activity level by 25 percent.

Build activity into your daily routine. Get up from your desk to deliver a message. Take the stairs instead of the elevator.

Record daily physical activity in a journal.

Don’t worry so much about weight loss. Realize if you are regularly active you can get significant health benefits even if you never lose a pound. People

Find activities you enjoy and feel good about doing.

Get the support of friends and family.

Finally, the biggest obstacle to successful lifestyle change is expectation. Set realistic expectations and recognize that any time is a good time to make a commitment to change your lifestyle.

"Chinese drywall" became part of the American lexicon several years ago and it was not long before a negative connotation became associated with it.

Domestic building materials were in short supply during the housing boom between 2004 and 2007 and in the wake of Hurricane Katrina. In an effort to fill the supply gap, drywall was imported, predominately from China, because it was cheap and plentiful. Soon thereafter, complaints arose regarding strong odors and respiratory ailments due to the elevated levels of airborne hydrogen sulfide and other sulfur compounds contaminated drywall has been found to emit. Likewise, the Consumer Product Safety Commission (CPSC) began fielding complaints regarding corrosion of metal items (i.e., refrigerator, electrical wiring, air conditioning evaporator coils, etc.). These health and corrosion complaints were concentrated in the southeastern U.S.; the elevated concentration of health and corrosion complaints have been attributed to the domestic drywall supply issues noted above and the findings that humid environments (i.e., the SE U.S.) tend to increase the production of these offgases.

The CPSC has recently published reports highlighting their findings from a 51-home indoor air study, non-destructive evaluations, as well as preliminary electrical, and fire safety components corrosion study findings. In summary, the studies found:

- The preliminary findings indicate that the imported drywall does not pose a severe health hazard to occupants. The CPSC cautions that the studies are not conclusive and more analysis is required.

- Using electron microscope imaging and chemical analysis of the observed corrosion on components, multiple forms of copper corrosion were observed. Two other forms of corrosion were analyzed. The electrical component samples had visual signs of corrosion of copper wiring. Even so, there were no indications of significant overheating of conductors or conductive parts due to the corrosion events.

Recently, there has been much confusion over the words "shall" ands "should" when interpreting OSHA standards and citations for employees working on road construction sites. The Occupational Safety and Health Act of 1970 (OSHA) imposes two basic duties on employers:

Generally, the OSHA standard (29 C.F.R s 1926.201(a)) for flaggers on construction sites incorporates the provisions of "warning garments" from the 2000 edition of the Manual on Uniform Traffic Control Devices (aka 2000 MUTCD) of the Federal Highway Administration (aka FHWA.) This standards requires that flaggers shall wear high visibility clothing. As for non-flaggers, the MUTCD states that employees working close to motor vehicle traffic should wear bright, highly visible clothing. OSHA defines "should" as meaning only "recommended."

In August 2009, OSHA issued a new interpretation on this topic that states, "failing to require construction workers to wear reflective vests in highway/road construction work zones would violate the General Duty Clause because such workers are "exposed to the danger of being struck by the vehicles operating near them."" This interpretation leads one to believe that OSHA could impose fines if non-flagging employees are not wearing reflective vests/clothing.

Historically, employers have concluded that the word "should" within OSHA standards and those referenced by OSHA are not enforceable with fines where the word "shall" was enforceable.

What are your thoughts on this topic? Should reflective vests be mandatory for all employee working on roadway construction sites? Are there any concerns about how this would affect your workplace? Let us know your thoughts.